Policy

The Code of Ethics sets out the principles of corporate conduct that must at all times inform every action by Etica Sgr employees in the name of the company.

Etica Sgr ensures that the Code of Ethics is widely disseminated, communicating its principles and values to all interested parties, so that they are applied in every decision. The employees of Etica Sgr were themselves involved in the drafting of the present Code.

The Code of Ethics applies to all Etica Funds staff or corporate bodies whatever their function or level of responsibility, within the framework of operations either internal or external to the company, in the conviction that ethical behaviour must be pursued equally by everyone with the same vigour as the success of the company.

In particular the company directors are obliged to adhere to the principles of the code in setting the company’s goals, recommending investments or realizing its plans.

The executives who give concrete form to the prescriptions of management, must adhere to the principles contained in the Code, reinforcing the spirit of mutual collaboration between all levels of the hierarchy.

All Etica Sgr employees are expected to be aware of the rules contained in the Code of Ethics and the related legislation that governs the activity of their department;  equally they must abstain from any practices contrary to such rules.

Legislative Decree no. 231 of 8 June 2001 governs the administrative responsibility of corporate bodies, companies and associations including those without legal personality, pursuant to Article 11 of Law no. 300 of 29 September 2000.

The Remuneration Policies and Practices document sets out Etica Fund’s rules on compensation and intends to guarantee the maximum transparency as regards the principles and mechanisms of remuneration within the company.

The document was approved by the shareholders’ meeting of April 29 2020 in Milan.

Etica has always considered the main negative impacts of its investment decisions on sustainability factors (“Principal adverse sustainability impacts”). The document is drafted in accordance with the provisions of EU Regulation 2019/2088.

Employees, members of governing bodies and in general all those who act in the name, and on the behalf of, the SGR, must try to avoid any possible conflict of interest.

By way of example, here are a few of the situations that can lead to conflicts of interest:

• participate in decisions regarding dealings with entities with whom the employee or a close family member has an interest or might have a personal interest;
• use the name of the SGR to obtain personal gain;
• recommend or accept any agreement from which personal gain might ensue;
• act, sign agreements or engage in any behaviour that might, directly or indirectly, bring damage to the SGR or the Group, including harm to its image or credibility with the markets;
• act against the interests of the SGR by influencing the decision-making independence of any subject responsible for defining commercial relationships with or for the SGR.